Burden Calculation Tables

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Overview

Summary
Table 1
Table 2
Capital O&M
Respondents
Responses

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Sheet 1: Summary

ICR Summary Information
Hours Per Response	27
Number of Respondents	417
Total Estimated Burden Hours	54,300
Total Estimated Costs	$11,000,000
Annualized Capital O&M	$3,590,000
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NSPS for Oil and Natural Gas Production and Natural Gas Transmission and Distribution (40 CFR Part 60, Subpart OOOO) (Renewal)
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Management	$172.41
3. Acquisition, installation, and utilization of technology and systems	N/A									Technical	$141.75
4. Report requirements	N/A									Clerical	$71.36
a. Familiarization with the rule requirements c	1	1	1	417	417	20.9	41.7	$65,680.21
b. Required activities
i. Notification of gas well completion d	0.5	33	17	0	0	0	0	$0
ii. Notification of gas well recompletion d	0.5	4	2	0	0	0	0	$0		Source Type	No.
iii. Notification of new gas processing plant e	1	1	1	0	0	0	0	$0		Existing	417
iv. Notification of new sweetening unit f	1	1	1	0	0	0	0	$0		Exploration/production	235
c. Create information	See 4B									Transmission/storage	107
d. Gather existing information	See 4E									Processing plants	91
e. Annual reports										Sweetening units	9
i. Gas well completion/recompletion d	16	1	16	0	0	0	0	$0		New	0
ii. Sweetening unit f	1	1	1	7	7	0.34	0.7	$1,063.96		Processing plants	0
iii. Centrifugal compressor g	8	1	8	31	246	12	25	$38,746.60		Sweetening units	0
iv. Reciprocating compressor h	8	1	8	1,314	10,512	526	1,051	$1,655,708.33		Updated using ratios from previous ICR.
v. Production pneumatic controller i	8	1	8	235	1,880	94	188	$296,112.22
vi. Gas processing pneumatic controller j	8	1	8	35	282	14	28	$44,416.83
vii. Storage vessel k	8	1	8	238	1,904	95	190	$299,892.38
f. Semiannual reports
i. Gas processing plant l	40	2	80	68	5,460	273	546	$859,985.49
Reporting Subtotal					23,814			$3,261,606
5. Recordkeeping requirements
a. Read instructions	See 4A
b. Plan activities	See 4B
c. Implement activities
i. Filing and maintaining records m	5	12	60	342	20,520	1,026	2,052	$3,232,033.38
ii. Filing and maintaining records n	5	12	60	100	6,000	300	600	$945,039.00
d. Record data	N/A
e. Time to transmit or disclose information
i. Records required by standards	See 5C
f. Time to train personnel	See 5C
g. Time for audits	N/A
Recordkeeping Subtotal					30,498			$4,177,072
TOTAL LABOR BURDEN AND COST (rounded) o					54,300			$7,440,000
TOTAL CAPITAL AND O&M COST (rounded) o								$3,590,000
GRAND TOTAL (rounded) o								$11,000,000
N/A - Not Applicable
a EPA estimates an average of 417 existing sources and no new sources will be subject to the standard over the next three years. Existing sources comprise 235 exploration and production businesses, 107 transmission and storage operations, 91 processing plants and 9 sweetening units. This number is expected to decrease over time as sources are modified or retired from service.
b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c This burden represents the time existing respondents spend re-familiarizing themselves with rule requirements, or that new respondents spend learning rule requirements.
d Initial notification and annual reporting for completions and recompletions is required for gas wells that commenced construction, modification or reconstruction after August 23, 2011, and on or before September 18, 2015. New gas wells or gas wells modified after September 18, 2015 and on or before December 6, 2022 are subject to 40 CFR 60, Subpart OOOOa. Facilities that commence construction, modification, or reconstruction after December 6, 2022 are subject to 40 CFR 60, Subpart OOOOb.
e Processing plants that commenced construction, modification or reconstruction after September 18, 2015 and on or before December 6, 2022 are subject to 40 CFR 60, Subpart OOOOa. Facilities that commence construction, modification, or reconstruction after December 6, 2022 are subject to 40 CFR 60, Subpart OOOOb.
f EPA estimates an average of 9 existing sweetening units and no new sweetening units. EPA estimates that 75% of those sweetening units will experience one reportable deviation per year. Sweetening units that commenced construction, modification or reconstruction after September 18, 2015 and on or before December 6, 2022 are subject to 40 CFR 60, Subpart OOOOa. Facilities that commence construction, modification, or reconstruction after December 6, 2022 are subject to 40 CFR 60, Subpart OOOOb.
g EPA estimates an average of 41 existing and no new centrifugal compressors equipped with wet seals at processing plants. EPA estimates that 75% of those centrifugal compressors will experience one reportable deviation per year. Centrifugal compressors equipped with wet seals at processing plants that commenced construction, modification or reconstruction after September 18, 2015 and on or before December 6, 2022 are subject to 40 CFR 60, Subpart OOOOa. Facilities that commence construction, modification, or reconstruction after December 6, 2022 are subject to 40 CFR 60, Subpart OOOOb.
h EPA estimates an average of 1,314 existing and no new reciprocating compressors. New reciprocating compressors that commenced construction, modification or reconstruction after September 18, 2015 and on or before December 6, 2022 are subject to 40 CFR 60, Subpart OOOOa. Facilities that commence construction, modification, or reconstruction after December 6, 2022 are subject to 40 CFR 60, Subpart OOOOb.
i EPA estimates 10,678 pneumatic controllers across the 235 exploration & production sites. EPA estimates that all 235 sites will experience one reportable deviation per year.
j EPA estimates an average of 47 existing and no new pneumatic controllers at affected processing plants. EPA estimates that 75% of those pneumatic controllers will experience one reportable deviation per year.
k EPA estimates an average of 238 existing and no new respondents in the production, processing, transmission, or storage segment will submit annual reports. EPA anticipates each report will cover approximately four storage vessels, based on research the Agency conducted during initial rule development.
l EPA estimates an average of 91 existing and no new gas processing plants. EPA estimates that 75% of those plants will experience one reportable deviation per year.
m Activity applies to exploration & production businesses and transmission & storage operations, for which EPA estimates an average of 235 and 107 sources, respectively.
n Activity applies to gas processing plants and sweetening units. EPA estimates an average of 91 existing processing plants and 9 existing sweetening units.
o Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NSPS for Oil and Natural Gas Production and Natural Gas Transmission and Distribution (40 CFR Part 60, Subpart OOOO) (Renewal)
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
Review initial notifications c										Labor Rates:
i. Notification of gas well completion	0.5	33	17	0	0	0	0	$0		Management	$76.91
ii. Notification of gas well recompletion	0.5	4	2	0	0	0	0	$0		Technical	$57.07
iii. Notification of new gas processing plant	0.5	1	1	0	0	0	0	$0		Clerical	$30.88
iv. Notification of new sweetening unit	0.5	1	1	0	0	0	0	$0
Review annual reports
i. Gas well completion/recompletion	1	1	1	0	0	0	0	$0
ii. Sweetening unit	1	1	1	7	7	0.34	0.7	$432.37
iii. Centrifugal compressor	1	1	1	31	31	1.54	3.1	$1,968.45
iv. Reciprocating compressor	1	1	1	1,314	1,314	65.70	131.4	$84,100.60
v. Production pneumatic controller	1	1	1	235	235	12	24	$15,040.82
vi. Gas processing pneumatic controller	1	1	1	35	35	1.76	3.5	$2,256.09
vii. Storage vessel	1	1	1	238	238	12	24	$15,232.83
Review semiannual reports
i. Gas processing plant	1	2	2	68	137	6.8	14	$8,736.86
TOTAL (rounded) c					2,300			$128,000
Assumptions:
a EPA estimates an average of 417 existing sources and no new sources will be subject to the standard over the next three years. Existing sources comprise 235 exploration and production businesses, 107 transmission and storage operations, 91 processing plants and 9 sweetening units. This number is expected to decrease over time as sources are modified or retired from service.
b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Initial notification is required for these source categories that commenced construction, modification or reconstruction after August 23, 2011, and on or before September 18, 2015. New gas wells or gas wells constructed, modified, or reconstructed after September 18, 2015 and on or before December 6, 2022 are subject to 40 CFR 60, Subpart OOOOa. Facilities that commence construction, modification, or reconstruction after December 6, 2022 are subject to 40 CFR 60, Subpart OOOOb
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Requirement	Capital/Startup Cost for One Respondent 3	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent 1, 3	Number of Respondents with O&M	Total O&M, (E X F)		CEPCI Index 2012	CEPCI Index 2023
SO2 CEMS (control outlet)	$99,635	0	$0	$23,339	9	$210,053		584.6	797.9
Continuous control device monitoring for centrifugal compressors 2	N/A	0	$0	$3,402	41	$139,482
Continuous control device monitoring for storage vessels 2	N/A	0	$0	$3,402	952	$3,238,704
Total (rounded) 4			$0			$3,590,000
CEM - Continuous Emission Monitoring System
N/A - Not Applicable
Assumptions:
1 Annual O&M costs for centrifugal compressors and storage vessels were calculated assuming 2 hours per month at $141.75 per hour.
2 Capital/Startup costs for continuous control device monitoring were included in storage vessel and centrifugal compressor control device costs.
3 Capital/Startup and Annual O&M costs have been updated from 2012 to 2023 using the CEPCI Index.
4 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	0	417	0	0	417
2	0	417	0	0	417
3	0	417	0	0	417
Average	0	417	0	0	417
1 New respondents include sources with constructed, reconstructed, and modified affected facilities. Facilities that commence construction, modification, or reconstruction after September 18, 2015 and on or before December 6, 2022 are subject to 40 CFR 60, Subpart OOOOa. Facilities that commence construction, modification, or reconstruction after December 6, 2022 are subject to 40 CFR 60, Subpart OOOOb.

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Sheet 6: Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Notifications a
Gas well completion	0	33	0	0
Gas well recompletion	0	4	0	0
New gas processing plant	0	1	0	0
New sweetening unit	0	1	0	0
Annual reports
Gas well completion/recompletion	0	1	0	0
Sweetening unit	7	1	0	7
Centrifugal compressor	31	1	0	31
Reciprocating compressor	1,314	1	0	1,314
Production pneumatic controller	235	1	0	235
Gas processing pneumatic controller	35	1	0	35
Storage vessel	238	1	0	238
Semiannual reports
Gas processing plant	68	2	0	137
			Total	1,996
Footnotes:
a These notifications are initial notifications for sources constructed, modified or re-contructed after August 2011 and prior to September 2015.
			hrs/response:	27